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Tanks Inside Of Buildings to Vent or Not to Vent, That is the Question

Scott Stookey, Senior Technical Staff, International Code Council Austin, TX

Some TankTalk readers may consider it inappropriate to misuse a common stanza from the Shakespeare
play The Tragedy of Hamlet and I hope the title doesnt offend you or inhibit your enjoyment of the
arts. However, the title paraphrases a question that is commonly asked of ICC staff because of the issues
surrounding AST installations inside of buildings.

The storage of flammable and combustible liquids in ASTs inside of buildings requires the fire code
official to apply more rigorous provisions from the 2012 International Fire Code

(IFC

) and NFPA 30,

Flammable and Combustible Liquids Code. For tanks designed to store liquids with a closed cup flash
point temperature below 200F (Class I, II and IIIA liquids) at atmospheric pressure, the requirements are
justified because flammable and combustible liquids exhibit much higher heat release and burning rates
when compared to many ordinary combustibles found in buildings. One of the requirements pertains to
the termination of normal vent and emergency vent of ASTs inside buildings, and thats the subject of this
article.

TINBIDS (Tanks Inside of Buildings) are fairly common in commercial development projects. Over the
past 10-15 years, the demand for standby power systems that provide an alternative source of electrical
energy to computer servers and similar equipment has increased dramatically. Designers commonly
specify engine-driven generators with integral sub-base ASTs to limit the floor area of the standby power
source. The TINBID requirements in Chapter 57 of the 2012 IFC become applicable when any AST
containing Class I, II or IIIA liquids is installed indoors. The IFC requires a construction permit to install
a TINBID as well as an operational permit to ensure that it is properly maintained in accordance with all
of the IFC requirements.

Normal Venting
In addition to the requirements for tank construction, volume limits and overfill protection, the IFC has
requirements for terminating a TINBIDs normal vent and emergency vent. The purpose of the normal
vent is to maintain the pressure inside of the tank when liquids are introduced into or are withdrawn. All
storage tanks are designed to resist the vacuum and positive pressures generated when liquid is introduced
into or withdrawn. Improperly sizing a tanks normal vent or obstruction ofthe vent can cause excessive
negative pressure to generate inside the tank, causing the tank to collapse into itself. IFC Section
5704.2.7.3 has a number of provisions to ensure the normal vents are properly terminated. For Class I, II
and IIIA liquids the IFC requires termination of the normal vent outside the building. It should be located
at least 12 feet above the finished ground level and a minimum of 5 feet from building openings and lot
lines that can be built upon. The 12-foot elevation of the vent is necessary to ensure that the surrounding
air mixes with the vapor being exhausted from the tank so the atmosphere is maintained below 25% of the
liquids lower flammable limit.

PV vents are required by IFC Section 5704.2.7.3.2 on the normal vents of TINBIDS containing Class IB
or IC liquids to limit the potential release of flammable vapors. A PV vent only operates when product is
withdrawn or added to the tank. In lieu of a PV vent, the 2012 IFC will now permit the installation of in-
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line flame arrestor. A flame arrestor is a mechanical device designed to absorb and dissipate the energy of
a flame. If a flame arrestor is selected as a means of protecting the tanks normal vent, it must be designed
and installed in accordance with API 2028. Note that when specifying flame arrestors, a number of
technical concerns must be addressed including:
Properly sizing the flame arrestor. A flame arrestor operates by absorbing heat using highly
conductive metal such as brass or aluminum installed so it fills the cross-sectional area of the vent
pipe. Improperly sized arrestors can obstruct the flow of air during liquid dispensing or
withdrawal operation. Such an obstruction can cause transfer pumps to cavitate or create a
vacuum pressure which could damage the primary containment.
Debris loading. Class I liquids commonly act as solvents and can be electrically conductive. As a
result, vapors with a positive electrical charge can attract and accumulate dust, dirt and other
debris. Because the solvent may adsorb or detract water, the removal of moisture causes the
debris to accumulate. The design of the normal vent needs to accommodate the maintenance and
cleaning of the flame arrestor of debris.

Emergency Venting
With the exception of ASTs larger than 12,000 gallons that contain Class IIIB liquids that are located so
they cannot be affected by a release of Class I or II liquids, IFC Section 5704.2.7.4 requires all TINBIDS
be equipped with a means of emergency venting. Emergency venting is a pressure relief device designed
to protect the tank from being overpressurized beyond its design limits so it does not rupture. The IFC
requires the emergency vent be installed and maintained in accordance with NFPA 30, Section 22.7.

Installation of a TINBID introduces additional requirements for the tanks emergency vent. The IFC
prohibits the discharge of an emergency vent inside a building. The primary reason for this provision is
the emergency vents function. When an emergency vent opens, it depressurizes the storage tank by
relieving vapor generated by a fire. This vapor, if not discharged outside the building, could add
vaporized fuel to an unwanted building fire. If enough vapor is released before it finds a fire or ignition
source, the resulting flash fire could create a vapor cloud explosion, causing severe damage to the tank
and building, as well as potentially injuring or killing building occupants.

An issue that impacts the design of emergency venting systems terminated outside a building is the
addition of pipe and fittings beyond the outlet of the storage tank can create a backpressure inside the
tank. This backpressure results from friction of the liquid vapor moving across the interior of the pipe and
fittings. NFPA 30 Section 22.7.4 requires piping that is extended more than 12-inches beyond the ASTs
emergency vent opening be evaluated for this pressure loss. Analysis routinely finds the pipe and fitting
diameters may need to be increased beyond the diameter of tanks emergency vent opening to
accommodate for this backpressure. The calculations are based on a derivative of the Darcy-Weisbach
equation as a result, the design of emergency vent extension piping should be supervised by a registered
professional engineer.

Because of the importance of emergency vents and the additional design challenges that arise for vents
protecting TINBIDS, the 2012 IFC was revised to permit the termination of the emergency vent inside the
building when combustible liquids are stored in protected aboveground storage tanks. A protected AST is
defined in IFC Section 202 as A tank listed in accordance with UL 2085 consisting of a primary tank
provided with protection from physical damage and fire-resistive protection from a high-intensity liquid
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pool fire exposure. The tank may provide protection elements as a unit or may be an assembly of
components, or a combination thereof. Exception 2 of IFC Section 5704.2.7.4 allows the emergency vent
to be terminated inside the building when the tank is storing Class II or IIIA combustible liquids. For
Class IIIB combustible liquids, the emergency vent has always been permitted to be terminated indoors.

The code was revised based on calculation of
vapor pressure of ultra low sulfur diesel stored
in a UL 2085 AST. As a condition of listing a
protected AST, UL 2085 prohibits the
thermocouple measuring the primary
containment from exceeding a maximum
temperature of 400F. Vapor pressure
calculations determined that at 400F, the vapor
pressure of the diesel is below the 2.5 PSIG
opening pressure specified in NFPA 30, Section
22.7.3.10.1. Based on the fire-resistance and
insulating quality of the materials used in the
fabrication of protected ASTs, the emergency
vent for these tanks storing Class II and IIIA
liquids will not operate inside a building.

The change in Section 5704.2.7.4 was developed in response to a code change that was approved in 2009
IFC. IFC Section 603.3.1 was modified to allow increased quantities of fuel oil inside of a building
without changing the occupancy to a Hazardous occupancy. The requirements in the 2009 IFC permit up
to 3,000 gallons of fuel oil inside a building when:

1. The fuel oil is stored in a Protected AST,
2. The entire floor housing the TINBID is protected by a NFPA 13 compliant automatic sprinkler
system,
3. The fuel oil piping system is designed and constructed in accordance with the International
Mechanical Code, and
4. The PAST is located not more than 2 stories below the buildings grade plane.

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Readers seeking additional information about changes to the 2012 IFC are encouraged to purchase the
Significant Changes to the 2012 IFC. This four-color illustrated soft cover provides a detailed analysis of
the purpose and intent of the significant code changes to the 2012 IFC. The book can be purchased from
the ICC Book Store at
http://www.iccsafe.org/Store/Pages/Product.aspx?category=15065&cat=ICCSafe&id=7404X12

******
ABOUT THE AUTHOR

Scott Stookey is a Senior Technical Staff member with the International Code Council. Scott previously
was the Fire Protection Engineer for the Phoenix (AZ) Fire Departments Special Hazard Unit and was an
Engineering Associate with the Austin (TX) Fire Department Hazardous Materials Engineering section. He
is a graduate of the Fire Protection and Safety Engineering Technology program at Oklahoma State
University and has over 20 years of experience in the areas of regulatory compliance and emergency
response. Mr. Stookey was formerly the Chairman of the NFPA 30A technical committee for motor vehicle
fueling and repair garages and a member of the NFPA 58 technical committee for liquefied petroleum
gases. Scott was also the former chairman of the legacy Uniform Fire Code development committee. He
is a member of Building and Fire Code Board of Appeals for the City of Austin.